SOC 2 P6.3: Creating & Maintaining Unauthorized Disclosure Records
Unauthorized disclosures happen. SOC 2 P6.3 requires you to detect, document, and maintain a complete audit trail of every breach or privacy incident. This control transforms reactive incident response into documented evidence of your privacy controls—essential for auditor confidence and customer trust.
What this means
P6.3 mandates that your organization establish and maintain accurate, timely records of all detected or reported unauthorized disclosures of personal information. This includes data breaches, accidental exposures, and third-party incidents. The records must be complete enough to demonstrate that you've met your privacy objectives and can account for every incident from discovery through resolution.
How to comply
- 1.Define what constitutes an 'unauthorized disclosure' in your organization—breaches, accidental exposure, insider threats, and third-party incidents.
- 2.Create a standardized incident reporting process that captures disclosure details: date discovered, type of information exposed, number of individuals affected, root cause, and remediation steps.
- 3.Implement a centralized log or system (spreadsheet, security tool, or GRC platform) to record every unauthorized disclosure with consistent metadata.
- 4.Document detection methods—how each incident was identified (internal audit, customer report, vendor notification, security monitoring).
- 5.Record investigation findings and corrective actions taken for each incident within a defined timeframe.
- 6.Retain disclosure records for the period required by your contracts and applicable privacy laws (typically 3+ years).
- 7.Review your disclosure log quarterly to ensure completeness and accuracy.
Evidence auditors look for
- Incident register or log showing date, type of disclosure, data elements involved, and resolution status
- Breach notification records and communications sent to affected individuals or regulators
- Root cause analysis documents for each unauthorized disclosure
- Remediation action plans tied to specific incidents
- Internal audit or security team reports identifying and classifying disclosures
- Third-party breach notifications received and your documented response
- Records retention policy specifying how long disclosure logs are maintained
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
GRCWatch automates unauthorized disclosure logging and lets you document, track, and remediate incidents in a tamper-proof audit trail—turning incident chaos into auditor-ready evidence.
See how GRCWatch handles this control automatically
Start free trial